Transferring an Award
When an investigator wishes to transfer a previously approved project to a new location, most sponsoring agencies have a process by which this transfer must occur. In many cases, including with the National Institutes of Health, the transfer request will receive administrative review to determine if it is appropriate and to determine the level of NIH funding. The decision to authorize transfer of the grant is often based upon criteria such as:
- If the project has been relinquished by the original institution
- If the facilities and resources at the new location allow for the successful performance of the project
- If the investigator plans any significant change(s) in research objectives and level of expenditures from those described in the previously approved project.
If the proposed change of institution does not meet these criteria, a competitive review may be required.
The specific steps required of faculty and staff at Emory will vary based on whether a grant is transferring into or out of Emory. The transfer of an existing grant will require activity by the PI at both the new institution and at the institution from which they are transferring.
When a grant transfers into Emory, the process mirrors the proposal submission process. The transfer application will need to be routed through the EPEX system as outlined in the Proposal Routing Section. The approvals to accept this incoming grants transfer will be obtained via EPEX. The PI should follow all agency policies for grant transfers and include any required materials in the EPEX system when routing. For the transfer of an NIH application, the following is needed:
The Principal Investigator must complete the PHS 398 Grant Application. This application will be sent to the attention of the appropriate NIH Grants Management Specialist. The face page of the grant application must include across the top of the page in capital letters, "CHANGE OF GRANTEE INSTITUTION." The PHS 398 Grant Application must include:
- A description of the facilities at the new institution and the probable effect of the move on the project;
- A detailed budget for the initial (transfer) budget period and, when future commitments exist, categorical budgets for those periods. Each budget should be based upon the previously recommended level(s). In the event of a mid-budget period transfer, the initial budget should be based upon the direct costs being relinquished by the original institution as reflected on form PHS 3734;
- A list of equipment (which was purchased in whole or in part with grant funds and had an acquisition cost of $1,000 or more) to be transferred from the original grantee institution. Such a listing in the application represents the new institution's acceptance of title to the transferred equipment.
- A progress report which will serve in lieu of a final progress report for the original institution.
- A statement concerning the current research plan and an indication of whether the original plan has been changed. If changed, provide appropriate details;
- Biographical sketches of all new professional personnel to be associated with the project;
- Other support pages for all key personnel , and;
- Special justification when requesting the transfer of a budget period with less that 6 months remaining.
Applications requesting the transfer of previously recommended support may be submitted without regard to the deadline dates indicated in the PHS 398 instructions. The application should, however, be submitted as early as possible to allow for our administrative review.
In addition to the steps taken at Emory University as the new institution, the Principal Investigator must work with their prior institution (the current grant recipient) to supply any needed documentation. For NIH grants, these include the Form PHS 3734 Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant. This form provides the effective date of relinquishment; the estimated Direct and F&A cost balances, and a statement of intent concerning the transfer of equipment.
In addition, Standard form 269, Financial Status Report will need to be completed by the original grantee institution and submitted. A third form, Form HHS 568, Final Invention Statement & Certification must also be completed and confirmation must be provided regarding any inventions resulting from the research
If a PI/PD wishes to transfer a grant out of Emory to a new institution, the PI/PD must obtain permission to transfer the grant award from the Chair of his/her department and from his/her school or unit business office. Upon securing permission to transfer the grant, the Emory Office of Grant and Contracts Accounting and Office of Sponsored Programs work together to complete any required forms or submit information required by the sponsor. For transfer of an NIH grant, this process includes the following documents:
- Form PHS 3734 Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant providing the effective date of relinquishment, the estimated Direct and F&A cost balances, and a statement of intent concerning the transfer of equipment;
- Standard form 269, Financial Status Report which is completed by the Office of Grants and Contracts;
- Form HHS 568, Final Invention Statement & Certification. This form must be completed and verified by the PI and submitted to OSP. OSP will then work with the Office of Technology Transfer to obtain the appropriate signature.
In addition to the processes undertaken at Emory, the PI/PD must follow all required processes at the new institution to submit the required materials to the sponsoring agency.
Occasionally, it may be necessary to change the PI on an award. OSP should be notified as soon as it is known that a change of PI will be needed. The documentation required will vary by sponsor, and according to the circumstances surrounding the change; however, in order to begin the process, OSP will need at minimum:
- Written notification and approval of the change from the current PI (unless circumstances render this impossible), the department chair, and the appropriate school business office.
- Written notification and approval from the proposed replacement PI, the department chair, and the school business office.
- If the PI and the replacement PI are in the same department and/or school, these approvals can be obtained simultaneously. If the new PI will be in a different department and/or school, separate approvals will be needed from each.
Once OSP has the required approvals, the analyst for the current PI's department will contact the sponsor to determine what information is needed and will request that information from the PI or departmental administrator.
Commonly requested documents include, but are not limited to:
- Biosketch for the proposed new PI
- Description of any budget changes resulting from the proposed change
- Confirmation of the effective date of the change
- Confirmation of any changes in the existing PI's effort prior to the date of change
- Confirmation of effort level for the proposed new PI
When all necessary documentation has been received, the OSP analyst will forward the request to the sponsoring agency.
Once the PI change is approved, if the grant will consequently be changing departments and/or schools, revised budgets may be requested, as this change will necessitate a change in SmartKey.